The UAE Federal Tax Authority (FTA) has issued a new Top-up Tax Guide on Scope and Registration, giving multinational enterprise (MNE) groups clearer direction on how the country's Top-up Tax applies and when they must register.
The guide explains how to determine whether a group falls within the Qualified Domestic Minimum Top-up Tax (QDMTT) legislation. It covers the conditions for scope, the entities that are affected and those that are exempt, and the registration process and timelines. It is aimed at those handling tax affairs for entities that may belong to an MNE group, as well as tax agents.
Practical examples address permanent establishments, joint ventures, flow-through entities and hybrid entities. The guide also covers the location of entities and the filing of the Pillar Two Information Return.
The Top-up Tax applies to UAE constituent entities of MNE groups with annual consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years. Groups operating exclusively within the UAE fall outside the scope, regardless of revenue.
The measure forms part of the OECD/G20 Two-Pillar Solution, which seeks to ensure in-scope groups pay an effective tax rate of at least 15% in each jurisdiction where they operate. The UAE introduced the QDMTT for fiscal years beginning on or after January 1, 2025, and was listed in the OECD central record on August 18, 2025 with "transitional qualified" status.
The FTA said the guide reflects its commitment to clear, practical guidance that supports voluntary compliance. It urged entities that may be part of an MNE group to read the guide in full and review their circumstances against the requirements. The guide is available on the FTA's official website.
News Source: Emirates News Agency
